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PUBLIC HEALTH ASSESSMENT

ENVIRO-CHEM CORPORATION
ZIONSVILLE, BOONE COUNTY, INDIANA


SUMMARY

The Envirochem Corporation (ECC) site is in Boone County, Indiana, about 5 miles north ofZionsville and 10 miles northwest of Indianapolis. This site borders the Northside SanitaryLandfill, another Superfund site.

Evidence exists that the site poses a public health hazard due to exposures which haveoccurredin the past, are presently occurring, or are likely to occur in the future. The estimated exposuresare to sodium, and potentially to chlorinated volatile organic compounds and inorganicsubstances found in the on-site groundwater, which could migrate to the private wells. Thesechemicals were found at concentrations in theresidential wells that, upon long-term exposures(greater than 1 year), can cause adverse health effects to any segment of the receptor population.

Potential exposure pathways exist for individuals involved in recreational activities in FinleyCreek, and to individuals eating aquatic life caught in Finley Creek. Because EnvirochemCorporation and Northside Sanitary Landfill are so close together, it is difficult to discern theactual source of contaminants. Remedial workers and plant employees are at risk of adversehealth effects if safety and health guidelines are not followed.

The community raised several non-health related questions about the remediation of the site. Health related questions primarily concerned the depth and types of contaminants found on-site.

The Indiana State Department of Health has made the following recommendations: 1)providefrequent monitoring of residential wells for contaminant migration in groundwater; 2) provideoff-site groundwater monitoring designed to ensure that no contamination reaches the residentialwells; 3) provide drinking water to households with sodium contaminated private wells; 4)inform residents with private wells of the possible health effects caused by the drinking of watercontaining high levels of sodium; 5) implement institutional controls in the near future toprevent the use of the contaminated aquifer for drinking water supplies; 6) inform area residentsof the potential danger of eating aquatic species taken from Finley Creek; 7) implement actionsfor monitoring or other removal and/or remedial actions needed to ensure that humans are notexposed to significant concentrations of site-related chemicals in the off-site surface water; 8)protect persons on and off the site from exposure to dusts or vapors that may be released duringremediation; 9) characterize off-site surface soil; and 10) provide remedial workers withadequate protective equipment and training in accordance with 29 CFR 1910.120.


BACKGROUND

A. Site Description and History

The Envirochem Corporation (ECC) site is in Boone County, Indiana, about 5 miles north ofZionsville and 10 miles northwest of Indianapolis (Figure 1, Appendix A). Farm land bordersthe southern edge of the site, and the Northside Sanitary Landfill (NSL) borders the eastern edgeof the site. NSL is also a Superfund site, but separate, and will not be addressed in this publichealth assessment except when referrals are made because of its close proximity to the ECC site. Residential properties are to the north and west.

The 6 ½-acre site is an inactive facility that processed and reclaimed solvents fromAugust 1977until May 1982 when the state closed the site. Wastes such as resins, paint sludges, waste oils,and flammable solvents were received in drums and bulk tankers and were stored on-site indrums and storage tanks. On-site accumulation and unauthorized discharge of contaminatedstorage water, poor management of drum inventory, unapproved burning of chlorinatedhydrocarbons and other solvents, and several spills (area of contamination not known) broughtthe state and the U.S. Environmental Protection Agency (EPA) to investigate the site. The stateprohibited the further shipment of waste to the site; however, over 26,000 drums and 400,000gallons of waste remained on-site. In addition, contaminated underground and abovegroundstorage tanks, and wastewater in holding ponds were present.

The site was placed on the National Priorities List (NPL) in September 1983. A Consent Decreewas negotiated in September 1983 between the EPA, the state of Indiana, and 246 potentiallyresponsible parties (PRPs), which included the establishment of a fund to finance the removalwork that the EPA began. The parties also agreed to perform the surface cleanup work at thesite.

Between March 1983 and August 1984, the EPA and a group of PRPs responsible for sitecontamination performed immediate actions that includedremoving and treating waste from on-site storage tanks, and removing and treating 5,650 cubicyards of contaminated soils. Actionswere also taken to prevent contaminated water from overflowing into off-site surface waters. InJuly 1983, bulk tanks and treated water from cooling ponds were removed in addition to 3,085drums and 167,000 gallons of liquid waste.

Between August and October 1984, further surface cleanup work took place. A holdingpondwas drained and capped, and the pond water was transported off-site to an approved facility fortreatment.

The contents of the on-site tanks were sampled and tested for compatibility. Compatible tankcontents were combined and the tanks were then dried and cleaned. Sludge from the tanks wasplaced into drums for removal and treatment off-site. Other underground tanks and pipes werelocated and recovered. The tanks containing PCBs were cleaned and rinsed. The entire site wasthen capped and seeded, and drainages were set up to control surface water runoff.

In March 1985, contaminated water was discovered ponded on the concrete cap at thesouthernend of ECC. It was determined that this water was runoff and not groundwater rising up throughthe concrete pad. During the resulting emergency action, a sump was constructed by EPA at thesoutheast corner of the site. A total of 20,000 gallons of contaminated water containing highlevels of VOCs were removed and disposed.

EPA conducted a Remedial Investigation/Feasibility Study (RI/FS) between 1983 and 1986. A preliminary health assessment was performed by the Agency for Toxic Substances and Disease Registry (ATSDR) inMarch of 1987. It was concluded that as a result of previous remedialactions at the site, the major sources of contamination had been removed; however, thereappeared to be individual areas of the site which would warrant further investigation todetermine their potential for further contamination. Recommendations were to perform furtherenvironmental monitoring to adequately assess the present condition of the site, surface waterquality, and domestic water supply wells; and to only consider the implementation of thoseremedial alternatives which reduce the potential for exposure and thereby protect public health.

EPA also completed an analysis of combined alternatives which evaluated comprehensivesolutions for the ECC site and the adjacent NSL site. Due to the proximity of the sites, thecombined analysis was performed to avoid duplication of effort, and to ensure that all remedialactions would be compatible and cost effective. (EPA Remedial Investigation/Feasibility Study)

Nine combined cleanup alternatives were considered for the two adjacent Superfund sites. Theselected alternative, which consists of an on-site leachate and groundwater collection andtreatment system, multi-layer cap, and access restrictions was documented in the original Recordof Decision (ROD) signed in September 1987. Once the original ROD was signed, EPA begannegotiating a settlement with the PRPs for the cleanup of both sites (EPA Record of Decision). A group of PRPs for the ECC site, known as the "settling defendants", accepted responsibilityfor cleanup of that site. The settling defendants, however, proposed using an enhanced soilvapor extraction (SVE) system rather than the groundwater collection and treatment systemprescribed in the original ROD. The EPA expressed interest, but was concerned about the SVEsystem's technical feasibility and performance. The settling defendants conducted a pilot SVEtest at the site in June 1988. The results indicated that a vapor extraction process couldsignificantly reduce the level of volatile organic compounds (VOCs) in the soil. Eventually, thesettling defendants offered to remediate the ECC site using an enhanced SVE system that wouldalso treat the extracted vapor. EPA and the Indiana Department of Environmental Management(IDEM) analyzed that offer and the information developed on the SVE, which led to the proposedROD amendments signed in June 1991 (EPA Record of Decision Amendments).

A primary reason for the proposed ROD amendment for the ECC site is to facilitateimplementation of separate remedies for the ECC and NSL sites, and to modify the selectedremedy for the ECC site. The major differences between the original remedy for the ECC siteand the remedy proposed in the ROD amendment are:

  • the use of an enhanced SVE system to remove and destroy on-site VOCs rather than a groundwater collection and on-site treatment system;
  • the addition of on-site health-based cleanup levels for soil and groundwater (these were not applicable to the original ROD); and
  • the use of a subsurface water collection system in the event the SVE system does notreduce on-site contamination to applicable levels within five years.

Key portions of the ECC site 1987 cleanup remedy that will remain the same are:

  • access restrictions implemented to control use of the site;
  • a multi-layer cap designed to prevent direct contact with contaminated soil and to reduce water infiltration;
  • off-site cleanup standards for surface water and groundwater, except that an additional cleanup standard will be added for PCBs; and
  • off-site subsurface and surface water monitoring designed to ensure that nocontamination reaches the unnamed ditch and Finley Creek.

A Consent Decree between EPA, the state of Indiana, and the ECC settling defendants wasentered in court in September 1991. After the Consent Decree and the ROD amendment havebeen finalized, the remedial design (RD) and remedial action (RA) phases will begin. (ConsentDecree)

During the RD/RA phases, technical drawings and specifications will be developed for theselected remedy and, after EPA approval, the remedial action will be implemented. The settlingdefendants have submitted all RD construction drawings and specifications to EPA for approval.

B. Site Visit

On June 12, 1992, Ms. Dollis Wright and Mr. Garry Mills of the Indiana State Department ofHealth (ISDH), and staff from IDEM and NSL (property owner) visited the site. During the sitevisit, we observed the following:

  1. The front gate to the fence surrounding the site was open. The site is accessible; however, only through the front entrance where the main office is located, and where all visitors are required to stop.
  2. There are two open structures (former office and process building) that are to be razed during remediation of the site.
  3. There were many storage tanks on-site (50-52 estimated). Some were empty (due to a removal action conducted in 1983), and some still contained tank bottom residues as explained by IDEM and NSL staff.
  4. There were three separate areas on-site that contained drums. One area was a concrete pad area for decontamination from past remediation activities. The drums (6 total) contain purged well water, soil boring material, and safety suits. The drums in the other two drum areas were either empty or their contents are unknown (100 total).
  5. The ECC site is well vegetated throughout.
  6. There was debris on-site including building materials and lumber.
  7. We observed the location where a pilot SVE study (in the proposed ROD amendment) was previously conducted in 1988-89 to determine whether vapors could be extracted from the soil.
  8. West of the site is a container facility which is a recycling operation owned by the NSL owner.
  9. The unnamed ditch water level was low during the site visit. We were told that the ditch is usually dry and that it is an intermittent stream (not permanent) which separates the ECC and NSL sites.
  10. We observed several monitoring well locations at the ECC site. Presently, there is onlyone well on-site. Additional monitoring wells have been installed off-site that were not apart of the final RI report released in March 1986.

On September 8, 1994, another site visit was conducted at the Enviro-Chem CorporationSuperfund site by Ms. Dollis Wright and Mr. Garry Mills of the ISDH. Also present were stafffrom the Indiana Department of Environmental Management.

The following are observations made during the site visit, and actions taken at the site as ofSeptember 8, 1994:

  1. The entire site is enclosed by a chain-link fence, but is accessible in some areas due to fencing not extending vertically all the way to ground level. Warning signs are posted.
  2. All on-site buildings and above-ground tanks have been dismantled and removed from the property.
  3. A support zone has been established which has a drainage ditch constructed around it to prevent surface run-off from the designated exclusion zone (contaminated area). The support zone has concrete underneath with gravel on top.
  4. There is possibly contaminants in the support zone, which is undergoing an investigation by IDEM staff, potentially resulting in a change of the Remedial Investigation.
  5. The exclusion zone includes a drum staging area on a concrete pad that has in excess of 170 drums. The drums are to be categorized (type of waste) and removed from the site this fall (1994) per IDEM staff.
  6. There is a decontamination storage pad area which has a sump pump pad next to it. There is standing rain water at both locations.
  7. The site has been graded and has vegetation growing on it. Gravel has been placed on all exposed land.
  8. Monitoring wells are on-site, but no monitoring is being conducted.
  9. Activities were observed at the Boone County Resource & Recovery System, Inc.recycling operation, which is adjacent (west) to Enviro-Chem.

C. Demographics, Land Use, and NaturalResource Use

Demographics

The 1990 Census showed the population of Boone County to be 38,147, and the populationofZionsville, which is 5 miles south of the site (nearest town to the site), to be 5,281. UnionTownship has a population of 1,707 with 569 households. It has a total of 889 males and 818females. The origin of race in Union Township is represented by the following: white (1,687);black (10); American Indian, Eskimo, or Aleut (5); Asian or Pacific Islander (5); and other race (0).

A small residential community, Northfield, is ¼ mile north/northwest of the site. Thenearestresidence is 600 feet from the site. Approximately 50 residences are within 1 mile of the site. The Northfield Community Church, along with several residences owned by the NSL privateowner's family, border the site. The site is closed for business and inaccessible to the public;therefore, remedial workers are the only population that currently go on-site.

Land Use

The site is in a rural area and is bounded on the south and east by farm land. The majority oftheresidences in the vicinity are north and west of the site. Farming, mainly cash grain andlivestock, is the main enterprise in the county. Corn, soybeans, and wheat are the main crops.

Natural Resource Use

Finley Creek flows east and south of the site, while the north and west sides drain into anunnamed ditch. This ditch lies between NSL and ECC. Finley Creek (less than 1 mile from thesite) flows into Eagle Creek about ½ mile downstream from the site. Eagle Creek flowssouthfor 10 miles before it empties into Eagle Creek Reservoir (9 miles from the site), which suppliesapproximately 6% of the drinking water for the city of Indianapolis. Surface water usedownstream, within 3 miles of the site, is used for fishing and wading by area residents. Theunnamed ditch and Finley Creek are very shallow in the immediate vicinity of the ECC site andtherefore not conducive for recreational activities. There are 1,760 persons within 3 miles of thesite who use private residential wells for all domestic purposes. The nearest residential well isabout 1,000 feet west of the site with a well depth of 40 feet.

Hydrogeology

In 1985, EPA conducted a very thorough hydrogeological investigation of the area aroundthissite. This investigation included, but was not limited to, reviews of existing information; asearch of historical aerial photographs, domestic and industrial well logs; and relevant literature. They then performed a subsurface exploration program to further define conditions at the site.

The major aquifers under the site are in sand and gravel deposits of glacial origin. Soil typesconsist of glacial tills, glacial outwash, and possibly some shallow alluvial deposits. The glacialtill consists predominantly of clayey silt and silty clay. The glacial outwash was made up of fineto coarse sand and gravel that are highly permeable. The alluvial deposit consists of fine sandand silty sand. The south end of the site is shallow and appears to be very complex, consistingof a combination of till, outwash, and alluvial deposits.

Four hydrological units exist beneath the site. They all appear to be fairly continuous:

5-15 feet - Saturated zone, thick silty clay zone; appears to have relative low permeability.
20-30 feet - Shallow sand and gravel; may be semi-confined in some places.
30-150 feet - Clayey silt and silty clay zone, which appears to act as an aquitard.
150-165 feet - A confined, deep sand and gravel zone just above the top of the rock surface.

The direction of water flow in the shallow and deep sand and gravel aquifers is, in general, to the south toward Finley Creek. Along the southeastern edge of the site, groundwater flow is toward the east, and discharges to the unnamed ditch.

The former cooling pond intersected both the shallow sand and gravel aquifers. Theseaquifersmay be semi-confined beneath much of the site due to lithologic variations between them andthe thick silty clay zone. This variation may decrease the migration potential of contaminantsfrom the saturated zone to the shallow sand and gravel zone.

D. Health Outcome Data

This section identifies the relevant, available databases; their evaluation occurs in the PUBLICHEALTH IMPLICATIONS section. Cancer may be a plausible health outcome from long-termexposure to at least one of the contaminants of concern. The ISDH maintains a statewide cancerregistry; however, data regarding cancer incidence by city and county are not yet available. Inaddition, the ISDH maintains a mortality database by county. Mortality data on Boone Countycancer deaths are available (1950-1979). The public health implications of these data will beevaluated in the Health Outcome Data Evaluation subsection.


COMMUNITYHEALTH CONCERNS

The following community health concerns were taken from the summary of a public meetingheld in April 1991 (EPA Public Meeting). The Boone County Health Department was contactedin March 1992 for any community health concerns in addition to those provided by IDEM.

  1. How about toluene, methyl ethyl ketone, trichloroethene, or something of that nature; do you see those at the site?
  2. What is the depth of contamination at the site?

The community health concerns listed will be addressed in the PUBLIC HEALTH IMPLICATIONS section of this public health assessment.

The health assessment was made available for public comment onJune 21, 1993. No additional health-related concerns were reported. Responses to all commentsreceived can be found in APPENDIX C.


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